Here at Comcast, bridging the digital divide has long been a priority for our company and a personal priority for me. OurInternet Essentials program is the nation’s largest and most comprehensive broadband adoption program. We have connected more than 500,000 low-income families – or over 2 million low-income Americans – to the transformative power of the Internet at home through this program -- multiple orders of magnitude more connections than all other private sector low income broadband programs combined.

We applaud the Commission’s efforts to modernize the Lifeline program to support broadband. We support the Commission’s efforts to simplify and streamline the rules for program entry and provider participation.

At the same time, the Commission must continue to take steps to eliminate waste, fraud, and abuse in the program. Recent FCC actions have helped in this regard, but as the Commission reforms Lifeline, it should, as with all universal service programs, do so in a financially responsible and cost-effective manner. The Commission must ensure that the Lifeline program meets its goals but also that the universal service fund as a whole does not impose an unreasonable burden on consumers. The fact that universal service is financed by U.S. consumers underscores the importance of that responsibility. The Commission’s proposal that eligibility and recertification functions currently performed by service providers are instead handled by a national verifier will help in this regard.

Even as the Commission moves forward with the important step of modernizing the Lifeline program, we must also recognize that the program only addresses one of the barriers to adoption. The success of Internet Essentials is due to its design as an integrated wrap-around solution that marries low-cost high-speed Internet access with training and education and access to a low-cost computer. The program is structured as a partnership between Comcast and thousands of school districts, libraries, elected officials, and nonprofit community partners to address the multiple barriers to adoption.

Rigorous quantitative research by the Census Bureau and NTIA, and economists at the FCC, has shown that the primary barrier to adoption is not the cost of the service, but rather is a bucket of digital literacy issues, including a perceived lack of relevance of the Internet and a lack of understanding as to its value or usefulness. For example, in October 2014, the NTIA, found that 48% of households who do not adopt broadband cited lack of need/lack of interest as the main reason. And last December, in its Home Broadband 2015 report, the Pew Charitable Trust found that 70% of non-adopters were not interested in subscribing to broadband in the future. Any proposed solutions must address all the different drivers of non-adoption.

Our experiences and the research on broadband adoption and utilization show that closing the digital divide is fundamentally dependent on a comprehensive approach that addresses digital relevance and digital literacy, the cost of computing equipment, and the cost of broadband service. We’ve learned that we will not move the needle on broadband adoption in this country unless there is a robust commitment to digital literacy and relevancy training.

Closing the digital divide is a great challenge, but I’m convinced that, by working together, we can get more Americans connected to the amazing and transformative power of the Internet. We share the Commission’s goal of modernizing the Lifeline program to bring broadband to those who otherwise cannot afford it. We look forward to learning more about the details of the Chairman’s proposal and hope to work constructively with the Commission on updating the Lifeline program as we confront the digital divide together.